INDIANA MICHIGAN POWER May 13, 2003

Indiana Michigan
Power Company
500 Circle Drive
Buchanan, Ml 49107 1395
INDIANA
MICHIGAN
POWER
May 13, 2003
Docket Nos:
AEP:NRC:3054-06
10 CFR 2.202
50-315
50-316
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Mail Stop O-PI-17
Washington, DC 20555-0001
Donald C. Cook Nuclear Plant Unit I and Unit 2
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION
REGARDING RELAXATION OF REACTOR PRESSURE VESSEL HEAD
PENETRATION INSPECTION REQUIREMENTS IN NUCLEAR
REGULATORY COMMISSION ORDER
Reference:
1)
U. S. Nuclear Regulatory Commission (NRC) Order
EA-03-009, "Issuance of Order Establishing Interim
Inspection Requirements for Reactor Pressure Vessel Heads at
Pressurized Water Reactors," dated February 11, 2003
2)
Letter from J. E. Pollock, Indiana Michigan Power Company
(I&M), to U.S. NRC Document Control Desk, "Donald C.
Cook Nuclear Plant Unit 1 and Unit 2, Request for Relaxation
from Nuclear Regulatory Commission Order Establishing
Interim Inspection Requirements for Reactor Pressure Vessel
Heads at Pressurized Water Reactors," AEP:NRC:3054-04,
dated March 26, 2003
This letter provides I&M's response to an NRC request for additional
information regarding the proposed relaxation of two reactor vessel head
penetration inspection requirements contained in an NRC order.
NRC Order EA-03-009 (Reference 1) established interim inspection
requirements for reactor pressure vessel head penetrations at pressurized water
reactors. In Reference 2, I&M requested relaxation from two requirements in
the order. The requirements from which relaxation was requested involve
nondestructive examination (ultrasonic, eddy current, and dye penetrant testing)
U.S. Nuclear Regulatory Commission
Page 2
AEP:NRC:3054-06
of penetration nozzles below the J-groove weld. The NRC requested additional
information regarding the requested relaxations in a telephone conference
conducted on April 28, 2003. Attachment 1 to this letter provides the
information request by the NRC, except that the response to one question is
applicable only to Unit 2. The response to that question includes a commitment
to provide the requested information for Unit 1 in a subsequent letter.
Attachment 2 provides graphs of stress versus distance below the J-groove weld
for Unit 2. Attachment 3 identifies the regulatory commitment made in this
letter.
I&M requests that the proposed relaxations
independently of the approval for Unit 1.
be approved for Unit 2
Should you have any questions, please contact Mr. Brian A. McIntyre, Manager
of Regulatory Affairs, at (269) 697-5806.
Sincerely,
J. E. Pollock
Site Vice President
JW/rdw
Attachments:
1. Response to Request for Additional Inforrnation
2. Stress Versus Distance Below J-groove Weld for Unit 2
3. Regulatory Commitments
c: Director, Office of Nuclear Reactor Regulation
H. K. Chernoff, NRC Washington DC
K. D. Curry, Ft. Wayne AEP, w/o attachments
J. E. Dyer, NRC Region III
J. T. King, MPSC, w/o attachments
MDEQ - DW & RPD, w/o attachments
NRC Resident Inspector
J. F. Stang, Jr., NRC Washington DC
U. S. Nuclear Regulatory Commission
Page 3
AEP:NRC:3054-06
AF FIRMATION
I, Joseph E. Pollock, being duly sworn, state that I am Vice President of Indiana
Michigan Power Company (I&M), that I am authorized to sign and file this
request with the Nuclear Regulatory Commission on behalf of I&M, and that the
statements made and the matters set forth herein pertaining to I&M are true and
correct to the best of my knowledge, information, and belief.
Indiana Michigan Power Company
E Pollock
Site Vice President
SWORN TO AND SUBSCRIBED BEFORE ME
TEl
/.
2003
DAY O°y)ve1
MCommisso
pNotarPublic
My Commission Expires
8^g^5oo=
JULIE E. NEWMILLER
Notary Public, Berrien County, Ml
My Commission Expires Aug 22,2004
U. S. Nuclear Regulatory Commission
Page 4
bc:
A. C. Bakken III, w/o attachments
G. F. Borlodan/C. R. Lane/K. R. Worthington
M. J. Finissi, w/o attachments
D. J. Gamer
J. B. Giessner
D. W. Jenkins, w/o attachments
J. A. Kobyra, w/o attachments
B. A. McIntyre, w/o attachments
J. E. Newmiller
J. E. Pollock, w/o attachments
D. J. Poupard
T. R. Satyan-Sharma
M. K. Scarpello, w/o attachments
C. L. Vanderniet
T. K. Woods
AEP:NRC:3054-06
ATrACHIENT 1 TO AEP:NRC:3054-06
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION
The documents referenced in this attachment are identified on Page 7.
Nuclear Regulatory Commission (NRC) Order EA-03-009 (Reference 1) established interim
inspection requirements for reactor pressure vessel (RPV) head penetrations at pressurized water
reactors. In Reference 2, Indiana Michigan Power Company (I&M) requested relaxation from
two requirements in the order. The requirements from which relaxation was requested involve
nondestructive examination (ultrasonic, eddy current, and dye penetrant testing) of penetration
nozzles below the J-groove weld. The NRC requested additional information regarding the
requested relaxations in a telephone conference conducted on April 28, 2003. This attachment
provides the information requested by the NRC, except that the response to one question is
applicable only to Unit 2. The response to that question includes a commitment to provide the
requested information for Unit 1 in a subsequent letter.
The information in this attachment is presented in two parts. Part 1 addresses the NRC questions
that apply to the proposed alternative to ultrasonic testing requirements specified in the order.
Part 2 addresses the NRC questions that apply to the proposed alternative to eddy current and
dye penetrant testing requirements specified in the order. In the responses discussing distances
below the J-groove weld, the J-groove weld is assumed to include the associated fillet weld as
shown on the attached sketch.
Part 1
Questions Pertaining to Proposed Alternative No. 1 to NRC Order EA-03-009:
Alternative to Requirement to Perform Ultrasonic Testing to Bottom of Nozzles
NRC Introduction
The licensee requested relief from performing ultrasonic testing of each RPV head penetration
nozzle (i.e., nozzle base material) from 2 inches above the J-groove weld to the bottom of the
nozzle.
NRC Question 1
The licensee stated that a small portion of base material will not be scanned on the bottom of the
nozzle because the lower transducer and the upper transducer of the probe need to be in contact
with the nozzle material. The distance from the bottom of the nozzle upward that cannot be
scanned is 12 mm. Please identify the minimum distance from the J-groove weld to the location
on the nozzle that cannot be scanned.
Attachment 1 to AEP:NRC:3054-06
Page 2
Response to NRC Question 1
As shown in the sketch provided at the end of this attachment, the distance from the bottom of
the nozzle upward that cannot be scanned due to the PCS24 probe transducer arrangement has
been calculated to be 12 millimeters (0.47 inches) plus the height of the chamfer (0.23 inches).
The minimum distance downward from the J-groove weld to the location on the nozzle that
cannot be ultrasonically scanned due to the PCS24 probe transducer arrangement has been
calculated to be 1.1 inches. Due to the curvature of the RPV head, this minimum distance only
occurs at one point on the downhill side of the outermost penetrations (six penetrations on Unit 1
and five penetrations on Unit 2).
NRC Question 2
Provide additional technical justification (i.e., operating stress levels, crack growth analysis, etc.)
that supports the licensee's statement that the small area that cannot be scanned is insignificant to
the phenomena of concern.
Response to NRC Question 2
The following response applies only to Unit 2. I&M will provide a response to NRC Question 2
for Unit 1 by separate correspondence as necessary to support the next Unit 1 under-head
inspection required by NRC Order EA-03-009, currently scheduled for Spring 2005. The
following response applies to the proposed alternatives to both surface examination (eddy current
and penetrant testing) and ultrasonic testing requirements in the order.
As described in NRC Order EA-03-009, the phenomena of concern are reactor coolant system
leakage through an RPV head penetration nozzle J-groove weld or through the nozzle base metal
above the J-groove weld caused by primary water stress corrosion cracking (PWSCC). These
phenomena can result in corrosion of the low-alloy steel RPV head resulting in a loss of coolant
accident, including ejection of the nozzle. I&M's conclusion that the small area that would not
be inspected (by ultrasonic, eddy current, or penetrant testing) is not significant to the
phenomena of concern is supported by the low operating stresses in that area, and an analysis of
the propagation time for a flaw in that area.
The operating stresses in that area are shown in Attachment 2 to this letter, which provides
graphs of hoop stress versus distance below the J-groove weld for various nozzles from the
center of the Unit 2 RPV head to the outermost row. As shown in these graphs, the stresses in
the area of the nozzle that would not be inspected are low relative to the yield stress of the nozzle
material (41,000 to 63,000 pounds per square inch).
Additionally, I&M has performed a calculation demonstrating that more than two operating
cycles would elapse before a postulated axial flaw in the area that would not be inspected would
propagate into the pressure boundary formed by the J-groove weld. The calculation was
performed using the methodology outlined by the NRC in Reference 3, and the American
Attachment I to AEP:NRC:3054-06
Page 3
Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. The flaw was
postulated to be 80 percent through the nozzle wall, since this is the maximum value given in
Table A-3320-2 in Appendix A to Section XI of the ASME Code. As stated in I&M's response
to NRC Questions 1 and 3, and NRC Question la in Part 2 below, the minimum distance below
the J-groove weld that would be inspected in accordance with the proposed alternatives has been
calculated to be approximately 1 inch. However, the flaw was conservatively postulated to be
0.5 inches below the J-groove weld in the flaw propagation calculation. The calculation
determined that the time it would take for a flaw to propagate from that location to the bottom of
J-groove weld would be at least 4.7 years. This time period is more than twice the minimum
under-head inspection interval for Unit 2 (one operating cycle) required by NRC Order
EA-03-009.
The results of the flaw propagation calculation indicate that, even if a flaw were to occur in an
uninspected portion of the nozzle, there would be adequate opportunity for detection prior to the
flaw reaching the reactor coolant system pressure boundary. These results, and the stress levels
shown in Attachment 2, demonstrate that the proposed alternatives (modified as described in the
responses to NRC Question 6 and NRC Question 2a in Part 2 below) provide reasonable
assurance of the structural integrity of the Unit 2 RPV head penetration nozzles and J-groove
welds. Therefore, the proposed alternatives, combined with the other provisions of the NRC
order, provide adequate protection against the phenomena of concern. Accordingly, I&M
considers that the proposed alternatives provide an acceptable level of quality and safety.
NRC Question 3
The licensee stated that at least five nozzles are threaded approximately 0.75 inches at the bottom
of the nozzle. Provide the distance from the bottom of the weld to the threaded area that cannot
be examined by UT. Additionally, please provide a more exact count of the nozzles that would
be affected.
Response to NRC Question 3
The minimum distance from the J-groove weld to the threaded area has been calculated to be
1.05 inches. Due to the curvature of the RPV head, this minimum distance only occurs at one
point on the downhill side of the outermost penetrations (labeled 50.50 in Attachment 2, six
penetrations on Unit 1, five penetrations on Unit 2). The minimum distance from the J-groove
weld to the threaded area for all other points on these penetrations, and for all points on the other
73 penetrations, exceeds this value. As indicated in the response to NRC Question 1 above, the
minimum distance from the J-groove weld to the location on the nozzle that cannot be
ultrasonically scanned due to the PCS24 probe transducer arrangement has been calculated to be
1.1 inches. Since this value is approximately equal to the 1.05 inch minimum distance to the
threaded area, the minimum distance from the J-groove weld to the location on the nozzle that
cannot be ultrasonically inspected due to both causes will be considered to be approximately 1
inch.
Attachment 1 to AEP:NRC:3054-06
Page 4
I&M has determined through visual observation that all 78 Unit 2 penetrations affected by the
proposed alternative are threaded. Six penetrations on Unit 1 are known to be threaded because
they have a thermocouple guide funnel installed on the threads. Fabrication drawings indicate
that all of the 73 other Unit 1 nozzles affected by the proposed alternative are also threaded, even
though they do not have guide funnels installed.
NRC Question 4
Since the order allows either UT or a surface examination, what would be the implications of
performing surface examination of the nozzle areas with limited UT coverage to provide 100%
coverage of all the nozzles, consistent with the requirements of the order?
Response to NRC Question 4
Based on the telephone conference with the NRC conducted on April 18, 2003, I&M understands
that the order allows combining ultrasonic testing and surface examination (eddy current and
penetrant testing) to achieve full coverage of a given nozzle. However, as described in the
responses to NRC Question 3 above and NRC Question la in Part 2 below, a threaded outer
surface would result in an undue hardship for both ultrasonic testing and surface inspection of
the lowest 0.75 inches of the nozzle.
NRC Question 5
The licensee is requested to provide a sketch of the nozzle with the necessary dimensioning to
clarify the areas covered by the request.
Response to NRC Question 5
A sketch has been provided at the end of this attachment.
NRC Question 6
The licensee stated that performing a UT examination to the bottom of the nozzle in accordance
with Order EA-03-009 would not provide relevant information to the phenomena of concern,
since some of the nozzles in the center area of the head extend approximately 5 inches below the
J-groove weld. The licensee is requested to provide technical justification that supports why this
portion of the nozzle does not need to be inspected, and why 2 inches below the J-groove weld
would be sufficient for testing. In particular, address the quality and safety aspects of not
inspecting beyond 2 inches below the weld.
Attachment 1 to AEP:NRC:3054-06
Page 5
Response to NRC Question 6
The alternative proposed in Reference 2 included a provision which would have eliminated
requirements to ultrasonically scan areas greater than 2 inches below the J-groove weld. This
provision was requested to preclude scanning unnecessary portions of the nozzles in the center
area of the RPV head, since the nozzles in this area extend well below the J-groove weld.
Although this provision can be justified, I&M has conservatively elected to eliminate the
provision. Accordingly, the proposed alternative is revised to be:
In lieu of requiring that ultrasonic testing of each RPV head penetration nozzle extend to the
bottom of the nozzle, I&M proposes that the ultrasonic testing conducted pursuant to
Sections IV.C(l)(b)(i) and IV.C(2)(b)(i) of NRC Order EA-03-009 be required to extend to
the lowest elevation that can be practically inspected with a PCS24 probe. The requirement
that ultrasonic testing extend to 2 inches above the J-groove weld would be unaffected. The
proposed alternative would not apply to the RPV level indication nozzle.
Part 2
Questions Pertaining To Proposed Alternative No. 2 to NRC Order EA-03-009:
Alternative to Requirement to Perform Eddy Current or Dye Penetrant Testing of All
Wetted Surfaces of Nozzle Base Material
NRC Introduction
The licensee requested relief from performing eddy current or dye penetrant testing based on two
considerations:
Consideration 1: The outside surface of at least five nozzles is threaded for approximately 0.75
inches at the bottom end of the nozzle. These nozzles have a guide funnel installed on the
threads and they are either drilled and pinned or stitch welded to securely fix it in position.
NRC Question la
Provide the distance from the bottom of the weld to the point where ET/PT cannot be performed.
Response to NRC Question la
The nozzles that have guide funnels installed are the outermost nozzles. As shown in the sketch
provided with this attachment, the guide funnels extend approximately 0.75 inches above the
threads. Consequently, the minimum distance from the J-groove weld to the location on the
nozzle that cannot be examined by eddy current testing or dye penetrant testing on nozzles that
have funnels installed is less that the distance assumed in the crack growth calculation described
Attachment 1 to AEP:NRC:3054-06
Page 6
in the response to NRC Question 2 in Part 1 above. Although the portion of the funnel extending
0.75 inches above the threads precludes eddy current testing and dye penetrant testing, it does
not preclude ultrasonic inspection. Therefore this area of the nozzles having guide funnels
would be inspected ultrasonically.
Although none of the other nozzles have funnels, visual observation of Unit 2, and fabrication
drawings for Unit 1 indicate that the other nozzles affected by the proposed alternative are also
threaded. The minimum distance from the J-groove weld to the threads for threaded nozzles
without funnels has been calculated to be 1.4 inches. Due to the curvature of the RPV head this
minimum distance would only occur at one point on the downhill side of the eight
next-to-outermost penetrations (labeled 47 0 in Attachment 2). The minimum distance from the
J-groove weld to the threads for all other points on these eight penetrations, and for all points on
the other 65 penetrations without funnels, would exceed this value.
The vendor performing nozzle inspections for CNP does not have an eddy current probe capable
of examining threaded surfaces. I&M estimates that penetrant testing these surfaces would
involve approximately 400 person-millirem per nozzle. Consequently, I&M believes that eddy
current or penetrant testing of threaded surfaces would result in undue hardship.
NRC Question lb
Describe the implications of removing the funnels and performing the surface examinations on
the threaded surface that currently cannot be examined.
Response to NRC Question lb
After the funnels were torqued during installation, they were pinned to the nozzle or were stitch
welded, forming a permanent attachment. The vendor's procedure for removal of a funnel, if
needed for a repair, would destroy the funnel, and a new funnel would have to be installed.
These operations would involve added time, monetary expenditure, and personnel radiation
exposure. Additionally, eddy current or penetrant testing of the threads exposed by removal of
the funnel would result in undue hardship as described in the response to NRC Question la.
NRC Introduction
Consideration 2: The second consideration is the elimination of the requirements to perform
eddy current or dye penetrant testing on portions of the nozzle that are not significant to the
phenomena of concern. The licensee states that some of the nozzles extend 5 inches below the
J-groove weld.
Attachment 1 to AEP:NRC:3054-06
Page 7
NRC Question 2a
The licensee needs to provide technical justification to support the statement that the area
5 inches below the J-groove weld is not a significant portion of the nozzle and a surface
examination would not be relevant. In particular, address the quality and safety aspects of not
inspecting beyond 2 inches below the weld.
Response to NRC Question 2a
This response addresses both NRC Question 2a and NRC Question 2b. The alternative
previously proposed in Reference 2 included a provision which would have eliminated
requirements to eddy current or penetrant test areas greater than 2 inches below the J-groove
weld. This provision was requested to preclude inspecting unnecessary portions of the nozzles in
the center area of the RPV head, since the nozzles in this area extend well below the J-groove
weld. Although I&M considers this provision to be justified, it has conservatively elected to
eliminate the provision. Accordingly, the proposed alternative is revised to be:
In lieu of requiring that all wetted surfaces of the J-groove weld and RPV head penetration
nozzle base material be subjected to eddy current or dye penetrant testing, I&M proposes that
the eddy current or dye penetrant testing conducted pursuant to Sections IV.C(l)(b)(ii) and
IV.C(2)(b)(ii) of NRC Order EA-03-009 be required for all wetted, non-threaded surfaces of
the J-groove weld and RPV head penetration nozzle base material. The requirement that
eddy current or dye penetrant testing extend to 2 inches above the J-groove weld would be
unaffected. The proposed alternative would not apply to the RPV level indication nozzle.
NRC Question 2b
The licensee needs to provide technical justification to support the statement that providing a
surface examination 2 inches below the J-groove weld is sufficient.
Response to NRC Question 2b
As described in the response to NRC Question 2a, I&M has revised the proposed alternative to
eliminate the provision that would have excluded areas greater than 2 inches below the J-groove
weld from surface examination requirements.
References
1. Nuclear Regulatory Commission Order EA-03-009, "Issuance of Order Establishing Interim
Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors,"
dated February 11, 2003
Attachment 1 to AEP:NRC:3054-06
Page 8
2. Letter from J. E. Pollock, Indiana Michigan Power Company, to U.S. Nuclear Regulatory
Commission, Document Control Desk, "Donald. C Cook Nuclear Plant Unit 1 and Unit 2,
Requests for Relaxation from Nuclear Regulatory Commission Order Establishing Interim
Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors,"
AEP:NRC: 3054-04, dated March 26, 2003
3. Letter from R. Barrett, NRC, to A. Marion, Nuclear Energy Institute, "Flaw Evaluation
Guidelines," dated April 11, 2003
Attachment 1 to AEP:NRC:3054-06
Page 9
Sketch of D.C. Cook Unit 1 and Unit 2 Reactor Vessel Head Penetration
(Not to Scale)
1l
/
0.23"
4
RPV Head Inside Surface
Note 1: Values referencing this note are minimum values, applicable to the downhill side of the
outermost penetration.
ATTACHMENT 2 TO AEP:NRC:3054-06
GRAPHS OF STRESS VERSUS DISTANCE BELOW J-GROOVE WELD
This attachment provides graphs of hoop stresses in reactor pressure vessel head control rod
drive mechanism (CRDM) penetration nozzles as a function of distance below the J-grove weld,
excluding the associated fillet weld, for Donald C. Cook Nuclear Plant Unit 2. The terms
"downhill" and "uphill" side refer, respectively, to the side of the penetration farthest and nearest
to the centerline of the reactor pressure vessel head. The degree () designation refers to the
angular displacement of the nozzle from the centerline of the reactor pressure vessel head, with
the "O° CRDM Penetration Nozzle" being the nozzle located in the center of the head.
Hoop Stress Distribution Below the Weld Downhill and Uphill Side
(00 CRDM Penetration Nozzle)
.
70,000
-L - - - - - J - - -
60,000
- -
- - - - -
I
4 0 ,0 0 0
- - - \i- -
.
mI
4030,000 ------
40,000
I
1
L
,
I
1
- - -- - -
1
- -
_
I
I
- - - - _- - - - - - - -
s1
--
_
- - - - -
I
- '- - - - - - - - - - _-L
-_ - - - - _
z~~~~~~~~~~~~~~
I
I
- - - - - -- -
- - - - - -- - - - - -
- -l - - - - - - - - - -
I
I
- - - --
- - - - --
- - - - --
_
-- - -
0
0
t0,000
--
--
--
--
-
--
--
--
_-
-
---
-
-
- --
--
-
-
- --
- -
. . ., .
-20,000
0.0
0.5
1.0
1.5
2.0
2.5
3.0
Distance from Bottom of Weld (in)
1-.-Inside -Outside
3.5
4.0
4.5
5.0
Attachment 2 to AEP:NRC:3054-06
Page 2
Hoop Stress Distribution Below the Weld Downhill Side
(27.00 CRDM Penetration Nozzle)
80,000
70,000
6000
50,0
- I
-
--
- - - -
- - -
'a. 40,000
-S
- -
--
-
-
-
-
-
-
-
-
-
-
- - -
30,000
0.
I
20,000
.
_
.
.
.
.
.
.a~~ .
10,000
0
-10.000
0.0
0.5
1.0
2.0
1.5
2.5
3.0
3.5
t.0
Distance from Bottom of Weld (n)
--- Inside --
usd
Hoop Stress Distribution Below the Weld Uphill Side
(27.00 CRDM Penetration Nozzle)
70.000
- - - - - - - - - - - - - - - - - - - -
- - - - - - - - - -- - -
---
- - -
60,000
- I
- - -
-
50,000
- -
-
40,000
'AC-
I
- - - -
- -I
-I I~~~~
- - - - - 4
~~
- --- - -- - - - - - - - - -~ -
30,000
(0
1 0,000
I~~~~
- - - -
*
I
- I~~~~~~~~- - - - -
- - -
I
0
-10,000
-20,000
-30.000
0.0
1.0
2.0
3.0
Distance from Bottom of Weld (in)
-- Inside U-usd
4.0
5.0
6.0
Attachment 2 to AEP:NRC:3054-06
Page 3
Hoop Stress Distribution Below the Weld Downhill Side
(45.80 CRDM Penetration Nozzle)
60,000
0.
n
40,000
0. 20,000
0.0
0.5
1.0
1.5
2.0
2.5
3.0
Distance from Bottom of Weld (In)
+- Inside --
Outside|
Hoop Stress Distribution Below the Weld Uphill Side
(45.80 CRDM Penetration Nozzle)
40,000
60.0
I
.
-40,000
-_- - - - - - -
- -- - - - - -
- - -- - -- -
I
-
'
- - - - - _- ,
0
r 20,000
\
''>
l\~~~~~~~~~
I
,
0.0
1.0
.
I
I
I
..
I
2.0
3.0
,
.
.
.
I
I
.I
...
I, ...
4.0
Distance from Bottom of Weld (in)
I-Inside -- Outside
5.0
6.0
7.0
Attachment 2 to AEP:NRC:3054-06
Page 4
Hoop Stress Distribution Below the Weld Downhill Side
(47.00 CRDM Penetration Nozzle)
120,000
-
100.000 -
80,000
- - - - - - - -
-
-
-
-
-
---
-
-
-
- -
-
-
- -- - - - - - --
- - - - -- - - - -
- -
-
- -
- - -- - - - -
60,000
-
40,000
-
-
ij
-
-
-
- -
-
- -
-
- -
-
-
-
-
-
-
-
-
- -
-
-
-
-
-
-
-
-
-
-
0.
CL
--
- - -
-
-
I
-
I
I~~~~~
-I
0
-20,000
0.0
0.5
1.0
3.0
2.5
1.5
2.0
Dlstance from Bottom of Weld (n)
I--Inside-Otid
Hoop Stress Distribution Below the Weld Uphill Side
(47.00 CRDM Penetration Nozzle)
80.000
C
-20,000 I
- - - - -I~~~~~~~~~~~~~
- -
I
I
I~~~~~~~~~
- - - - -
I
- - -
4)
0,000
-6,0
-
-
0.0
-
-- -
- - - -r
-
-
- - -
-- - -
- - - -
- -
-I
1.0
2.0
3.0
4.0
5.0
Distance from Bottom of Weld (in)
--Inside -- Outside
6.0
7.0
8.0
Attachment 2 to AEP:NRC:3054-06
Page 5
Hoop Stress Distribution Below the Weld Downhill Side
(50.5° CRDM Penetration Nozzle)
100,000
~
--I
80,000
-
~
~
\
60,000
\
-_
-
-_
-
-
~
~~
~
~~
~
- - - -
- - - -I
-__
-__-_ - _
-_
_
-
-
-- -
-_
_
_
-
~
- -_
~
~
~
_
- -
-
-
-
-
-
_
_ _
-
- -
- _
__--
- _
__--
_
__--
0.
,,, 40,000 -
- - - -
e
-
8
20,00000-20.0002
nnn
-
0.5
0.0
2.0
1.0
1.5
Distance from Bottom of Weld (in)
2.5
-Outside
I -Inside
Hoop Stress Distribution Below the Weld Uphill Side
(50.50 CRDM Penetration Nozzle)
80,000
60,000-
I
i
i
,
I
I
l
l
l
,
,
,
.
I
.
!
,
.
U,
.
.
.
.
.
|
,
I
,
,
,
l
,
I
I
,
,
.
.
.
.
.
.
.
,
,
,
.
,
.
.
.
.
.
.
,
,
,
I
,
,
,
&
,
I
,
I
,
l
'
,
'
I
I
'
l
-------r-------,---|<----,--------1--------1--------,--------,-------\
CL
\
0.
\
,
|
|
,
|
\
\
\
\
l
l
\
ew
,
_ _ __ __1_ - __ _ _ _ _1_- -__ - -_
_ \_____L_ _ ___ __L _ _ _ _ _ _ _1_\ ___ __1__ _ _ _ _ _ _1_
0.
\
cn
\
\
0
0
_ _ - -\-
\,
=
I\
I
IX
I
I <
...
0.0
I
1.0
-'
...
2.0
I
G
...
I
I
I
I
I
I
I
I
I
....
,
I
I
I
-
I
I
3.0
4.0
5.0
Distance from Bottom of Weld (in)
|-0-Inside --
Outside
_
I
________
_______I________I___
I
I
_ _ _ _ _ _, _ _ _ _ _ _ _
a_
I
I
_______I________I____
______L
7
l
,
I
I
_ - - - -
- - - - - - -|
,
,
I
I
'
I
- - - - - - - t - - - - - - -,-
l
\
_e
I
,
I
I
,
I
I
,
l
\
I
I
V
z
I
I
I
I
I
I
I
I
I
I
'
6.0
.
2
......
7.0
|
8.0
ATTACHMENT 3 TO AEP:NRC:3054-06
REGULATORY COMMITMENTS
The following table identifies those actions committed to by Indiana Michigan Power Company
(I&M) in this document. Any other actions discussed in this submittal represent intended or
planned actions by I&M. They are described to the Nuclear Regulatory Commission (NRC) for
the NRC's information and are not regulatory commitments.
Date
Commitment
the next Unit 1
As
necessary
to
support
to
NRC
Question
2
I&M will provide a response
under-head inspection required by NRC
in Part 1 for Unit 1.
Order EA-03-009, currently scheduled for
Spring 2005.